San Diego Law Review


Library of Congress Authority File


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The due process clause of the Fourteenth Amendment has been held to prohibit the deprivation of a constitutionally protected property interest without "appropriate procedural safeguards."' The California Court of Appeal for the Fourth District recently decided what procedural safeguards were appropriate for a post-termination hearing following the discharge of a public employee. In Townsel v. San Diego Metropolitan Transit Development Board, the court held that all public employees removable only for cause are entitled to a full, trial-like post-termination evidentiary hearing where the government employer must prove its case against the discharged employee. This Casenote questions the Townsel court's holding.

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